IRS Issues Revised Guidance on Form W-2 Reporting Requirements for Costs of Employer Group Health Coverage
23 January 2012
Mayer Brown Legal Update
The Patient Protection and Affordable Care Act of 2010 (PPACA) requires employers to report the aggregate cost of “applicable employersponsored group health care coverage” (referred to herein as “Reportable Coverage”) on employees’ Forms W-2 in Box 12 using code DD. On October 12, 2010, the US Internal Revenue Service (IRS) issued Notice 2010-69, which waived the reporting requirements for Forms W-2 required to be issued for 2011, although employers could voluntarily elect to report for 2011. On March 29, 2011, the IRS issued Notice 2011-28, which provided interim guidance that was intended to address some of the issues relating to the reporting requirements and to assist employers in complying with the requirements.